e-manifest: What You Need to Know Missouri Waste Seminar 15 Nov 2017

Transcription

1 e-manifest: What You Need to Know Missouri Waste Seminar 15 Nov 2017

2 Why connect better? Using existing and emerging monitoring and information technologies, EPA, states, regulated facilities, and the public are better able to find and fix pollution problems. Increased transparency, more comprehensive data from electronic reporting, and advanced monitoring allows innovative approaches. EPA, States, and Tribes can better identify joint problems presented by large regulated universes. Problem solving approaches that go beyond traditional single facility inspections and enforcement. Better protect public health and the environment, assure a level playing field for businesses that play by the rules, engage communities, and reduce regulatory burdens.

3 e-manifest Overview The Electronic Hazardous Waste Manifest System (e-manifest) is a new system targeted for June 2018 implementation that will allow: Industry Hazardous Waste Handlers to submit Uniform Hazardous Waste Manifest Forms, either electronically or on paper, to EPA States/Regions to retrieve the collected manifest data electronically E-Enterprise and e-manifest Will use other systems under e-enterprise including: Resource Conservation and Recovery Act Information System (RCRAInfo), Central Data Exchange (CDX) and electronic signatures Align with Administrator s Cooperative Federalism Vision for effective partnerships with states and tribes. Support Agency-wide initiative to reduce reporting burden, and provide the agency, states and the public with easier access to environmental data. Anticipated Result EPA estimates the national e-manifest system will ultimately reduce the burden associated with preparing shipping manifests by 300,000 to 700,000 hours and result in cost savings of more than $90 million per year for states and industry.

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5 e-manifest will be mobile connected Anything you can do on a computer, you can do on a phone

6 e-manifest is a Multi-Faceted Project System Development System launch in June 2018 Regulatory Development Final rule establishing user fee methodology in December 2017 Implementation and Communication Working to prepare states and industry for transition to e- Manifest Advisory Board Meets at least once a year; last meeting in September 2017 focused on user registration

7 Top Five Things You Need to Know about e-manifest 1. e-manifest will launch in June System is and will be available for testing through Spring e-manifest will take effect everywhere at the same time. 3. All destination facilities that receive hazardous waste or state-only hazardous waste on a manifest must submit those manifests to EPA either in paper or electronically An associated fee will be charged for each manifest submission. 4. Once the system launches, states, tribes, and the public can receive manifest data from e-manifest. 5. Handlers will be required to register for e-manifest to submit electronically and to make corrections. 7

8 Scope of e-manifest Affects any waste shipped on a manifest. RCRA federal hazardous waste PCB waste shipped on a manifest State-regulated hazardous waste (if manifest required by state) Very Small Quantity Generator waste (if manifest required by state) Imported hazardous waste One exception: hazardous waste exports will not be included in e-manifest at this time. 8

9 Scope of e-manifest New obligations for destination facilities receiving waste on a manifest. Hazardous waste permitted treatment, storage, and disposal facilities Other receiving facilities accepting waste on a manifest (e.g., Subtitle D disposal facilities, recyclers without a permit) Other types of entities that can create, edit, and/or sign electronic manifests Generators Transporters Brokers preparing manifests 9

10 Scope of e-manifest: Non-Hazardous Wastes Current Solution e-manifest will allow for the listing of non-hazardous wastes on paper and electronic manifests e-manifest will store the information, but will not validate the data beyond basic validation to ensure the data is submitted in a proper format States/Regions will receive non-hazardous waste data along with other manifest data

11 Current Focus of e-manifest for June 2018 Launch Date Manifest process Highway shipments of manifested waste. Domestic shipments and imports For the future Rail/Air/Barge shipments of manifested waste. Exports Integration with Biennial Report 11

12 Implementation Work Group EPA has established an implementation work group that consists of EPA HQ staff and Regional Points of Contacts. The EPA Regions will play a very important role in helping implement e-manifest in their region by assisting their states: Identify how their current hazardous waste manifest statutes, regulations, and/or business practices will need to change to align with e-manifest; Adopt the e-manifest rules as soon as possible Engage their regulated community Raise concerns and questions to the e-manifest work group for consideration Ensure state access to e-manifest data

13 Regional Programmatic and Technical Points of Contact (POCs) for e-manifest Implementation 13

14 What We ve Done So Far Reviewed state-only hazardous waste codes. Identified state points of contact who will work with their Regional POC to prepare their regulatory agency and regulated community for e-manifest. Focused on identifying receiving facilities that accept state-regulated waste for treatment/disposal, as they will have to submit manifests to EPA Presented at RCRAInfo Conference. FAQs published online. Communicated website:

15 What Industry Needs to Do Thousands of generators, transporters, and receiving facilities will apply into a RCRAInfo industry application (MyRCRAid and/or BR) as Site Managers. Site Managers gain automatic access to e-manifest later. Site Managers then approve users within their companies, greatly reducing the associated burden. 15

16 Status of e-manifest User Fee Final Rule The draft User Fee final rule is now with OMB, for its 90 day EO and Interagency Review. The Final Rule is on track for publication in the Federal Register in December Schedule is intended to allow 180-day interval between publication and effective date. 16

17 What the User Fee Rule Does Presents EPA s methodology for determining, revising, and announcing applicable e-manifest user fees, Our goals: A durable methodology that will prevail without numerous rules, A simple schedule of fees that accomplishes full cost recovery, Per manifest fees based on processing costs of each manifest type. Resolves several non-fee matters raised in proposed rule: Changing transporters on manifest while shipment in en route. Use of mixed paper/electronic manifests (the hybrid ), Describes a process for correcting existing data records in system Explains implementation and authorization requirements for state programs, and Announces effective date for system and rules. 17

18 Other Key Issues for Final Rule 1. Which manifest or data users will be charged fees? 2. Which transactions will be charged fees? 3. Should there be a chemical security based restriction on data disclosure to the public? 4. Should the fee formula pivot to more aggressive fees for paper manifest use? 5. What payment methods will be allowed? 6. What sanctions will be imposed for non-payment? 7. What process for resolution of fee disputes? 8. Should we prohibit facilities form mailing paper forms? 18

19 EPA is planning to provide information on the following: 1. How can brokers engage in e-manifest/sign on behalf of generators? 2. How will interstate shipments work when the generating state/receiving state doesn t require a manifest? 3. How much will EPA charge to process manifests? 4. How can states receive data from the e-manifest system? 5. How long will EPA keep manifest data? 19

20 Upcoming events The next e-manifest public webinar is scheduled for November 29, 2017, at 2:00 PM (EST). For information on access or services for individuals with disabilities, and to request accommodation of a disability, please send an to emanifest@epa.gov six days prior to the meeting to give EPA adequate time to process your request. 20

21 Contact us Submit input/questions to To subscribe to the general program Listserv send a blank message to: emanifestsubscribe@lists.epa.gov For more information on EPA s Manifest Program: 21

22 Questions? 22